July 26, 2025
Office of the Chief Clerk
Texas Commission on Environmental Quality
MC-105
P.O. Box 13087
Austin, TX 78711-3087
RE: Public Comment and Request for Public Meeting and Contested Case Hearing – TPDES Permit Renewal No. WQ0001481000 (DeCordova Steam Electric Station – Luminant Generation Company LLC)
Dear Chief Clerk and Commissioners,
I am submitting this formal public comment and request for both a public meeting and a contested case hearing regarding the proposed renewal of TPDES Permit No. WQ0001481000, which authorizes Luminant Generation Company LLC to continue discharging wastewater from the DeCordova Steam Electric Station into Lake Granbury.
As the elected Precinct 211 Chair in Hood County and a resident living adjacent to a waterway that flows directly into Lake Granbury, I am directly and personally impacted by the operation of this facility. The proposed discharge includes once-through cooling water, stormwater runoff, metal cleaning wastes, and previously monitored effluent—up to 1.04 billion gallons per day—directly into a designated public water supply and high aquatic life segment of the Brazos River Basin.
I observe the nesting and flight patterns of bald eagles along the lakefront near my home. Continued wastewater discharges without enhanced monitoring, modern filtration, and accountability jeopardize federally protected species and pose serious health and environmental risks. I am especially concerned for the residents of my precinct, including vulnerable populations such as children and the elderly, who rely on Lake Granbury for recreation, drinking water, and economic livelihood.
It is not scientifically sound or ethically responsible to evaluate the impacts of this discharge in isolation. The surrounding region is already burdened by significant industrial air pollution from Wolf Hollow I and II, the proposed Wolf Hollow III gas plant, and the Marathon Digital crypto mine. These sources contribute to cumulative air and water pollution burdens affecting the same receptors: our lungs, our water, our ecosystems, and our families.
Accordingly, I respectfully request the following:
1. A formal public meeting be held to provide transparency and ensure community concerns are heard;
2. A contested case hearing be granted to review this permit in light of community-specific harms;
3. A requirement that the applicant produce and publish updated monitoring reports of all effluent components;
4. An order requiring cumulative impact assessment of this and other industrial facilities discharging into Lake Granbury or impacting its watershed;
5. A full environmental and wildlife impact study with particular focus on bald eagle nesting habitat.
The permit, as currently drafted, fails to account for these overlapping harms and places my community at significant risk.
Thank you for your attention and for the opportunity to raise these important issues.
Sincerely,
Dr. Shannon Wolf
Precinct 211 Chair, Hood County
Phone: +1 (817) 564-1114
Email: Profswolf@gmail.com
Protect Hood County
We use cookies to analyze website traffic and optimize your website experience. By accepting our use of cookies, your data will be aggregated with all other user data.